Exigent circumstances

Question 1

Welsh v. Wisconsin,

Answer 1

Facts
On a rainy evening in April 1978, Edward G. Welsh was observed driving erratically and eventually abandoned his vehicle in an open field. A witness, concerned for safety and suspecting Welsh of either severe intoxication or illness, contacted the police after Welsh declined assistance and walked away. Police arrived, identified Welsh as the car’s owner, and proceeded to his nearby home without a warrant. They entered the home, found Welsh in his bedroom, and arrested him for driving under the influence, a non-jailable traffic offense. Welsh refused a breath-analysis test at the police station. The state trial court, bypassing the issue of consent for home entry, found exigent circumstances justified the warrantless arrest, a decision later upheld by the Wisconsin Supreme Court.

Issue
The primary legal issue in this case was whether the Fourth Amendment prohibits police from making a warrantless nighttime entry into a person’s home to arrest him for a nonjailable traffic offense, and under what circumstances, if any, such an entry would be justified.

Holding
The U.S. Supreme Court held that the warrantless entry into Welsh’s home to arrest him for a nonjailable traffic offense was prohibited by the Fourth Amendment. The Court vacated the judgment of the Supreme Court of Wisconsin and remanded the case for further proceedings consistent with its opinion.

Question 2

Brigham City v. Stuart

Answer 2

Facts
In Brigham City, Utah, early on the morning of July 23, 2000, police were called to address complaints about a loud party. Upon arrival, officers heard shouting from inside the residence and proceeded to investigate. Observing through a screen door and windows, they witnessed an altercation in the kitchen involving four adults attempting to restrain a juvenile. The situation escalated when the juvenile struck one of the adults, causing visible injury. Despite their presence being announced, the altercation continued until the police made their way into the kitchen, at which point the violence ceased. The officers arrested the respondents for contributing to the delinquency of a minor, disorderly conduct, and intoxication. The respondents filed a motion to suppress the evidence obtained following the police’s entry, claiming it violated the Fourth Amendment. The trial court granted this motion, and the decision was affirmed by the Utah Court of Appeals and the Supreme Court of Utah.

Issue
The central issue before the Supreme Court was whether police officers may enter a home without a warrant when they have an objectively reasonable basis to believe that an occupant is seriously injured or imminently threatened with such injury.

Holding
The Supreme Court held that law enforcement officers may enter a home without a warrant to render emergency assistance to an injured occupant or to protect an occupant from imminent injury. Therefore, the officers’ warrantless entry into the home was justified under the circumstances, reversing the judgment of the Supreme Court of Utah.

Question 3

Lange
v. California

Answer 3

Facts
Arthur Lange drove past a California highway patrol officer while playing loud music and honking his horn, which attracted the officer’s attention. The officer initiated a pursuit and signaled for Lange to pull over. However, Lange was near his home and chose to continue into his driveway and garage instead of stopping. The officer followed Lange into his garage without a warrant, conducting a field sobriety test that Lange failed, leading to charges for driving under the influence (DUI) and a noise infraction. Lange moved to suppress evidence obtained after the officer’s entry, arguing the warrantless entry violated the Fourth Amendment.

Issue
Does the pursuit of a fleeing misdemeanor suspect always, or categorically, justify a warrantless entry into a person’s home under the exigent circumstances exception to the Fourth Amendment’s warrant requirement?

Holding
No, the pursuit of a fleeing misdemeanor suspect does not always justify a warrantless entry into a home. The exigencies of each case must be considered to determine if warrantless entry is justified, based on specific facts and circumstances, rather than applying a categorical rule.

Question 4

Kentucky v. King,

Answer 4

acts
This case involves a search conducted by police officers in Lexington, Kentucky.
The officers were conducting a controlled buy of crack cocaine outside an apartment complex.
After observing a drug deal, they followed a suspect towards an apartment building.
Mistaking the apartment from which they smelled marijuana for the suspect’s destination, the officers knocked on the door, announced their presence, and heard movements inside that they interpreted as the destruction of evidence.
They subsequently forcibly entered the apartment, finding not the initial suspect but Hollis Deshaun King and others, along with visible illegal drugs.
King challenged the warrantless entry and search on Fourth Amendment grounds, arguing that the police had created the exigent circumstances they used to justify the search without a warrant.

Issue
The central issue before the Supreme Court was whether the exigent circumstances rule, which allows for a warrantless search to prevent the destruction of evidence, applies when the police’s actions (knocking on the door and announcing their presence) cause the occupants to attempt to destroy evidence.

Holding
The Supreme Court held that the exigent circumstances rule does apply in such situations, reversing the Kentucky Supreme Court’s decision.
The Court ruled that the police’s conduct before entering the apartment was lawful and did not violate or threaten to violate the Fourth Amendment.
Consequently, the exigency justified the warrantless search of the apartment.